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NASSTRAC Opposes Higher Class Ratings on Unitized Shipments

May 11, 2011

NASSTRAC, an industry association that represents the interests of freight shippers in all modes of transportation, has expressed its opposition to the proposal by Roadrunner Transportation Services to modify Item 640 of CCSB Docket No. 2011-2, Section 1, Subject 9. The proposal would lead to unwarranted higher class ratings on pallets, platforms, racks or skids used with most mixed unitized shipments. This opposition was expressed in a letter to the National Motor Freight Traffic Association's Commodity Classification Standards Board May 4, 2011.

Roadrunner argues, in support of its proposal, that the current rule, under which such pallets or skids are assigned the same class rating as the lowest-rated commodity shipped on the pallet or skid, is objectionable because there might be other commodities on the pallet or skid whose transportation characteristics are more "representative" of the characteristics of all the goods being shipped, according to the letter.

This proposal makes no sense, either as a matter of logic or as a matter of CCSB policy, said John Cutler, NASSTRAC's legal counsel. "If a mixed pallet included a preponderance of goods with stowability, liability or handling issues, would it make sense to assume that the pallet or skid has similar characteristics? Obviously not."

There is also no evidence of record that NASSTRAC sees to support any contention that the current rule leads to assigning inaccurate class ratings to pallets and skids, or that Roadrunner's proposal would lead to assigned ratings that come closer to class ratings reflecting actual pallet densities than the current rule, said Cutler. "NASSTRAC believes the proposal would lead to less accurate class ratings that are higher than warranted under acceptable CCSB policies and practices."

According to NASSTRAC's letter to the NMFTA, the support for the proposal appears to be inadequate and speculative or anecdotal, and the reasoning appears fallacious. NASSTRAC joined Waddington North America, Inc., a NASSTRAC member, in urging CCSB to reject Roadrunner's proposed change in Item 640.